More than three months into the 2018 MIPS (Merit-based Incentive Payment System) reporting year, the Centers for Medicare and Medicaid Services has finally updated the Participation Lookup Tool to reflect 2018 eligibility.
Providers can check their MIPS participation status by entering their NPI in the eligibility tool. The information returned will show eligibility for both the 2017 and the 2018 reporting years, separated into tabs. Eligibility status is indicated for both individual and group reporting for each TIN the provider is associated with. As well, any special statuses affiliated with the practice is indicated in the results.
Some providers who were required to participate in 2017 may not be eligible (or required) to participate in 2018 because the guidelines changed. Individual MIPS eligible clinicians or groups with $90,000 or less in Part B allowed charges or 200 or fewer Part B beneficiaries are excluded from the program. For year one, the threshold was $30,000 in Part B allowed charges or 100 Part B beneficiaries. According to a recent article by Fiercehealth, CMS estimates that the new guidelines will exclude more than 500,000 clinicians from MIPS this year.
Provider groups have complained to CMS about the late notification regarding MIPS eligibility. The Lookup Tool wasn’t updated until April in 2017, either, for that MIPS reporting year. But at least 2017 was a transition year. With CMS’s “Pick Your Pace” program, even those who hoped to get an incentive could choose a 90-day reporting period and still be successful. For 2018, the Quality reporting category has a 12-month reporting period.
Also, according to the American Medical Association (AMA), CMS has indicated there will be a significant delay in fully updating the Quality Payment Program website for 2018, with some information not expected until the summer at the earliest. These two delays have prompted the AMA, the Medical Group Management Association, and other provider groups to urge CMS to reduce the 2018 MIPS quality measure reporting period to a minimum of 90 consecutive days.
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